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Case 1:20-cr-00330-PAE Document 295 _ Filed 05/25/21 Page 19 of 26 time the defendant was indicted in July 2020 or at the time Jeffrey Epstein was indicted in 2019. Specifically, although Minor Victim-4 had previously been interviewed once in or about 2007 in connection with a prior investigation conducted by the USAO-SDFL, Minor Victim-4 did not agree to be interviewed by the prosecution team handling this case until July 2020. The Government then conducted two preliminary interviews with Minor Victim-4 by video teleconference in the summer of 2020. Because of the difficult nature of the interview topics, however, the Government was not able to fully debrief Minor Victim-4 over video. Due to travel constraints and safety concerns arising from the COVID-19 pandemic, the Government was unable to travel to meet with Minor Victim-4 until late January 2021, at which time the Government conducted multiple in-person interviews with Minor Victim-4. The Government then took additional investigative steps and sought the S2 Indictment in late March 2021, approximately two months after concluding its debriefing of Minor Victim-4. Simply put, the S2 Indictment was brought in a timely manner upon the Government’s collection of evidence to support the additional charges. Any suggestion that the Government intentionally delayed obtaining the S2 Indictment to gain some strategic advantage has no basis in fact. The defendant has not established—and cannot establish—an undue delay, much less an intentional and deliberate delay caused by the Government for an improper purpose. Finally, the defendant again asks the Court to “defer consideration of this motion until trial.” (Def. Mot. at 22). The Court should again reject the defendant’s invitation to defer ruling on this motion. See Apr. Op. at 18 (denying motion but allowing renewal of motion if the “factual record at trial shows otherwise’); see also United States v. Muric, No. 10 Cr. 112 (LTS), 2010 WL 2891178, at *1 (S.D.N.Y. July 13, 2010) (“The motion to dismiss the Indictment as the result of pre-indictment delay is therefore denied, without prejudice to appropriately supported later motion 15 DOJ-OGR-00004726